DHW v. Jane DoeAnnotate this Case
Mother Jane Doe appealed a magistrate court’s termination of her parental rights to her child T.G.E. At the time she gave birth, Mother had pending felony drug charges and an active warrant for her arrest; the child’s umbilical cord tested positive for methamphetamine at birth. Following a termination hearing, the magistrate court found termination proper based on neglect and entered an order to that effect on December 8, 2017 (the Order). However, in a subsequent decree (the Decree) issued on December 15, 2017, the magistrate court stated Mother’s parental rights were being terminated based on abandonment. The court also terminated Father’s parental rights however, Father had voluntarily relinquished his parental rights and was not a party to this appeal. On appeal, both Mother and the Department raised procedural issues relating to the conflicting Order and Decree. Subsequently, the Idaho Supreme Court remanded the case for entry of a new judgment terminating Mother and Father’s rights to Child, and stated the Order would constitute the findings of fact and conclusions of law. Mother appealed, contenting the magistrate court erred when it terminated Mother’s parental rights. Finding no reversible error, the Supreme Court affirmed the ultimate termination.